CSAs

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William Byrnes (Texas A&M University Law)

Byrnes' Analysis of the 200+ page Amazon Decision. Is it the Death Knell of the Income Method and Inclusion of Employee Stock Compensation for Cost Sharing Agreement Valuation?

March 24, 2017

In a 207 page opinion the Tax Court ruled March 23, 2017 that the IRS’s adjustment with respect to Amazon.Inc's transfer pricing buy-in payment for an intragroup cost sharing agreement (CSA) is…

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